Interpretation ID: aiam2418
III
Division Manager
Universal Imports
14622 Southlawn Lane
Rockville
Maryland 20850;
Dear Mr. Matthews: This is in response to your September 13, 1976, letter concerning ' line of racing/rally tires that are not Department of Transportation marked.'; I understand from your recent telephone conversation with Mar Schwimmer of my staff that the tires with which you are concerned are of the following size designations: 165/70 HR 10, 225/60 HR 14, 225/60 HR 13, and 195/70 HR 13.; Section S6 of Federal Motor Vehicle Safety Standard No. 109, *Ne Pneumatic Tires--Passenger Cars*, reads as follows:; >>>S6. *Nonconforming tires*. No tire of a type and size designatio specified in Table I of Appendix A that is designed for use on passenger cars and manufactured on or after October 1, 1972, but does not conform to *all the requirements of this standard*, shall be sold, offered for sale, introduced or delivered for introduction in interstate commerce, or imported into the United States, for any purpose. (emphasis added)<<<; because the size designations of the tires in question all appear i Table I of Appendix A, these tires are subject to the prohibitions of S6 unless they were manufactured before October 1, 1972. 'All the requirements of the standard' include both performance and labeling requirements.; Sincerely, Frank A. Berndt, Acting Chief Counsel